Follow-up to a Human Rights Compliance Audit in Mongolia

Location: Mongolia

Client:Multinational mining company

The Problem: The client had acquired an asset without doing a human rights review before purchase. A number of labor-related issues affecting the Chinese workforce were identified following acquisition, and the client needed to upgrade the site to meet its commitments and obligations. An audit had been carried out, and 6 months later the client wanted to follow up and ensure that the issues had been addressed effectively and in-line with their human rights commitments.

What we did: We undertook a site-level review of the issues identified in an internal human rights audit carried out by the client. This involved engaging with representatives of the Chinese workforce, as well as Mongolian staff on the site. We looked individually at the issues identified in the audit, which covered overcrowding of workers in accommodation areas, sanitation conditions, access to food, and allegations of potential forced labor. In order to make sure that minimum standards were being met, we quantified requirements and rolled out a review process and spot-checks across the site.

We identified where issues had been addressed and where gaps remained. For outstanding human rights issues, we defined concrete steps that the company needed to take to address them.

Outcome:Improved conditions for the Chinese workforce and actionable next steps for the company.

Feasibility assessment of the potential for the roll-out of the VPSHR in Myanmar

Location: Myanmar

Client: The in-country Voluntary Principles on Security and Human Rights (VPSHR) signatories and the VPSHR Secretariat, financed by the PeaceNexus Foundation.

The Problem: The VPSHR Secretariat wanted to understand the value-added, opportunities and challenges for rolling out the VPSHR at national-level in Myanmar. There was already a group of VPSHR members and signatories in the country, and in order to proceed, they decided to establish an in-country implementation pilot group and see what could be achieved by them.

What we did: We kick-started the process with a thorough review of the experience of implementing the VPSHR in Myanmar to-date, as well as developing a stakeholder engagement plan to prepare for in-country consultations. This was followed by stakeholder consultations in-country with 25 national and regional companies, NGOs, civil society organisations, multilateral agencies, foreign governments and industry bodies. In addition, we ran small group discussions with key informants. The preliminary findings were discussed in a reflection workshop. Recommendations and findings were prepared in a report, which was submitted to the in-country team.

Outcome: Development of a strategy to roll out the VPSHR in-country, which was funded by several groups in Myanmar for implementation.

Investigation into allegations of indirect terrorist financing of a mine in Afghanistan

Location: Afghanistan and Pakistan

Client:Multinational mining company

The Problem: Allegations had been made of a significant risk that the client was contributing to indirect terrorist financing via commodities that were sourced from Afghanistan. The client needed to verify allegations, trace commodities, and assess what transactions were taking place in the supply chain.

What we did: The client wanted to verify allegations as quickly as possible. We mobilised a team within two weeks that could safely conduct this sensitive research in remote mine sites in Afghanistan and follow the commodity through to Western markets. Specifically, we:

• Reviewed what was already known in terms of the commodities being sourced.

• Trained the field team in conflict sensitive field research and investigations and implemented our Health, Safety, and Security protocols for the team.

• Quickly deployed the teams into Taliban and ISIS controlled areas and documented who controlled which mines.

• Followed the commodities on donkey and trucks through the mountains and into stock yards, and mapped transactions along the way.

• Followed the commodity into Pakistan and the supplier warehouse. Here we investigated allegations of supplier corruption and unethical behaviour.

• Conducted background checks and due diligence on the different individuals in the supply chain.

• Presented findings within four weeks.

Outcome: The assessment was carried out safely, and insight shared with the client. We developed a roadmap for the client to tighten up supply chain controls.